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EPA Has Sufficiently Managed Emergency Responses During the Pandemic but Needs to Procure More Supplies and Clarify Guidance Report No. 20-E-0332 September 28, 2020
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Cleaning up and revitalizing land
Report Contributors: Tina Lovingood
Steve Hanna
Jonathan Morrand
Kate Robinson
Brenda Vazquez-Fuentes
Abbreviations
EPA U.S. Environmental Protection Agency
OIG Office of Inspector General
OLEM Office of Land and Emergency Management
OSC On-Scene Coordinator
PPE Personal Protective Equipment
Cover Photo: Abandoned drums at the Hall Street Superfund emergency response site in
St. Louis, Missouri, on May 6, 2020. (EPA image)
Are you aware of fraud, waste, or abuse in an EPA program? EPA Inspector General Hotline 1200 Pennsylvania Avenue, NW (2431T) Washington, D.C. 20460 (888) 546-8740 (202) 566-2599 (fax) [email protected] Learn more about our OIG Hotline.
EPA Office of Inspector General 1200 Pennsylvania Avenue, NW (2410T) Washington, D.C. 20460 (202) 566-2391 www.epa.gov/oig Subscribe to our Email Updates Follow us on Twitter @EPAoig Send us your Project Suggestions
20-E-0332 September 28, 2020
Why We Did This Project We performed this evaluation to determine whether the U.S. Environmental Protection Agency managed its resources for emergency responses to provide continued protection of human health and the environment during the coronavirus pandemic—that is, the SARS-CoV-2 virus and resultant COVID-19 disease. We also sought to examine whether the EPA provided sufficient protective measures to its on-scene coordinators, or OSCs, who respond to emergency incidents. We sent surveys to 239 OSCs in June 2020 and received responses from 127—a 53 percent response rate. We also interviewed all ten EPA regional Superfund and Emergency Management Division directors, as well as directors from the EPA’s Office of Emergency Management. This report addresses the following:
• Cleaning up and revitalizing land.
This report addresses a top EPA management challenge:
• Maintaining operations during pandemic and natural disaster responses.
Address inquiries to our public affairs office at (202) 566-2391 or [email protected].
List of OIG reports.
EPA Has Sufficiently Managed Emergency Responses During the Pandemic but Needs to Procure More Supplies and Clarify Guidance
What We Found EPA regions sufficiently protected human health and the environment by responding to emergencies or assisting in emergency responses during the coronavirus pandemic. In addition, the Agency took some initial measures to protect OSCs. For example, starting in March 2020, when the EPA began adjusting its operations because of the coronavirus pandemic, the Agency reviewed its ongoing and time-critical emergency responses, delaying responses when possible to do so without further detriment to public health or the environment. Also, some OSCs who normally would have been deployed were instead able to work remotely with state and local responders to verify that the emergency responses were adequate. The OSCs who responded to our survey, however, expressed concerns that the EPA did not provide sufficient protective measures or effectively manage its emergency responses:
• About half reported that the coronavirus pandemic impacted their ability to respond to emergencies. Some cited delays in procuring personal protective equipment and cleaning supplies, while some said there were delays due to the additional time needed to obtain approval for deployment.
• All said that the EPA did not provide COVID-19 tests to them before or after deployment.
• Although almost all indicated that they were familiar with the EPA’s health and safety guidance, some said that they had issues complying with the guidance, and some said that they needed clarifications on the guidance.
OSCs and management sometimes had different observations. For example, regional Superfund and Emergency Management Division directors said that personal protective equipment and other supplies were provided to OSCs. These directors also told us about the implications of the coronavirus pandemic on the Agency’s impending emergency responses. Specifically, a director in one western region stated that the region may be unable to respond to large incidents because of a lack of N95 masks, which the region deems necessary for wildfire responses.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA implement a strategy to provide necessary personal protective equipment and cleaning supplies to OSCs, including N95 masks; develop communications mechanisms to address OSCs’ safety concerns; clarify its pandemic guidance; and provide COVID-19 tests to OSCs being deployed. The Agency agreed with one recommendation but disagreed with the other three.
U.S. Environmental Protection Agency Office of Inspector General
At a Glance
OSCs may not be safe deploying during the pandemic without sufficient personal protective equipment and clear guidance.
September 28, 2020
MEMORANDUM
SUBJECT: EPA Has Sufficiently Managed Emergency Responses During the Pandemic but Needs to
Procure More Supplies and Clarify Guidance
Report No. 20-E-0332
FROM: Sean W. O’Donnell
TO: Peter Wright, Assistant Administrator
Office of Land and Emergency Management
This is our report on the subject evaluation conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this evaluation was OA&E-FY20-0240.
This report contains findings that describe the problems the OIG has identified and corrective actions the
OIG recommends. Final determinations on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
We make four recommendations in this report. In accordance with EPA Manual 2750, your office
provided acceptable planned corrective actions and estimated milestone dates in response to
Recommendation 2. This recommendation is therefore resolved.
Action Required
The Office of Land and Emergency Management disagreed with Recommendations 1, 3, and 4, and
provided alternate recommendations, but these alternate recommendations either did not include specific
planned corrective actions or did not adequately address our findings. These recommendations therefore
remain unresolved. We request a written response to the final report within 60 days of this memorandum.
Your response will be posted on the OIG’s website, along with our memorandum commenting on your
response. Your response should be provided as an Adobe PDF file that complies with the accessibility
requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The final response should not
contain data that you do not want to be released to the public; if your response contains such data, you
should identify the data for redaction or removal along with corresponding justification. If resolution is
still not reached, the Office of Land and Emergency Management is required to complete and submit a
dispute resolution request to the chief financial officer.
We will post this report to our website at www.epa.gov/oig.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
EPA Has Sufficiently Managed Emergency 20-E-0332 Responses During the Pandemic but Needs to Procure More Supplies and Clarify Guidance
Table of Contents
Purpose ........................................................................................................................ 1 Background ................................................................................................................. 1 Responsible Offices .................................................................................................... 4 Scope and Methodology ............................................................................................. 4 Results ......................................................................................................................... 5
EPA Has Sufficiently Managed Emergency Responses During the Coronavirus Pandemic .................................................................... 6
Some OSCs Experienced Delays in Obtaining PPE and Supplies ......................... 7 EPA Needs to Plan for Large Natural Disaster Incidents ........................................ 8 OSCs Familiar with Guidance but Need Some Clarifications.................................. 9
Conclusions ................................................................................................................. 10 Recommendations ...................................................................................................... 10 Agency Response and OIG Assessment .................................................................. 11 Status of Recommendations and Potential Monetary Benefits .............................. 12
Appendices A OSC Survey Results........................................................................................... 13 B Agency Response to Draft Report ................................................................... 18 C Distribution ......................................................................................................... 28
20-E-0332 1
Purpose
The Office of Inspector General
conducted this evaluation to
determine whether the
U.S. Environmental Protection
Agency managed its resources for
emergency responses to provide the
continued protection of human
health and the environment during
the coronavirus pandemic—that is, the SARS-CoV-2 virus and resultant
COVID-19 disease. We also sought to determine whether sufficient protective
measures were provided to on-scene coordinators, or OSCs.
Background
In response to the coronavirus pandemic, every level of government—federal,
state, tribal, territorial, and local—has engaged in efforts to slow and stop the
spread of the COVID-19 disease through a multitude of initiatives, including
stay-at-home orders; travel restrictions; use of personal protective equipment, or
PPE; and adherence to guidelines issued by the Centers for Disease Control and
Prevention. At the same time, EPA emergency response and support capabilities
need to be available to support natural disaster responses, including those needed
during the 2020 hurricane and wildfire seasons. The Agency’s responsibilities for
implementing federal environmental laws also continue, even as resources and
capabilities shift to address the ongoing pandemic and any emergency responses.
According to the EPA’s website:
EPA’s emergency response program responds to oil spills,
chemical, biological, radiological, and nuclear incidents and
large-scale national emergencies, including homeland security
incidents. EPA provides support when requested or when state
and local first responder capabilities have been exceeded.
Through coordinating and implementing a wide range of
activities, EPA conducts removal actions to protect human health
and the environment.
The EPA’s emergency responses are managed through the deployment of OSCs,
who are located in all ten EPA regions. The Agency’s OSCs are responsible for
monitoring or directing responses to all oil spills and hazardous substance releases
reported to the federal government. OSCs also coordinate responses with local,
state, and regional response authorities.
Top Management Challenge
This evaluation addresses the following top management challenge for the Agency, as identified in OIG Report No. 20-N-0231, EPA’s FYs 2020–2021 Top Management Challenges, issued July 21, 2020:
• Maintaining operations during pandemic and natural disaster responses.
20-E-0332 2
EPA Issued Multiple Coronavirus Pandemic Guidance Documents
The Office of Land and Emergency Management, along with other EPA offices,
produced four key documents to guide OSC work during the coronavirus
pandemic.
On March 19, 2020, OLEM published the Office of Land and Emergency
Management Considerations and Posture for COVID-19 Pandemic to ensure that
it could carry out its Primary Mission Essential Function, which is “to prevent,
limit, mitigate or contain chemical, oil, radiological, biological, and hazardous
materials during and in the aftermath of an accident, natural or man-made disaster
in the United States, and provide environmental monitoring.”
On April 10, 2020, OLEM and the Office of Enforcement and Compliance
Assurance published Interim Guidance on Site Field Work Decisions Due to
Impacts of COVID-19. This interim guidance supplements the March 19, 2020
guidance and provides additional criteria to be considered when determining
whether site fieldwork should continue or be suspended at emergency response
sites where the EPA is the lead agency or has direct oversight of the cleanup
work. According to this interim guidance, the EPA should make decisions about
continuing on-site activities on a case-by-case basis based on following priorities:
• Protecting the health and safety of the public, as well as maintaining the
health and safety of EPA staff and cleanup partners. Integral to the
protection of health and safety is the adherence to any federal, state, tribal,
or local health declarations and restrictions, to the extent possible.
• Maintaining the EPA’s ability to prevent and respond to environmental
emergencies, or in any situation necessary to protect public health and
welfare and the environment.
On April 21, 2020, the EPA published the Interim Health and Safety Guidelines
Related to COVID-19 for Conducting Superfund Site Work. OLEM’s EPA
Response Health and Safety Workgroup developed these guidelines to provide a
consolidated list of safety and health practices for OSCs and other EPA field staff
to implement during the COVID-19 public health emergency. The guidelines
include recommendations on:
• Medical clearances, including up-to-date medical and respiratory
protection clearances.
• Deployment considerations, such as assessing the work environment and
wearing PPE.
• Site safety, including monitoring for illnesses, enforcing safety measures,
and implementing procedures for illness or injury.
20-E-0332 3
• Workplace exposure to COVID-19, including instructions on when cases
must be recorded.
• Travel-related recommendations, such as advising that staff obtain
EPA-approved disinfectants and instructing staff how to disinfect cars and
hotel rooms.
• Workers’ compensation, including information on medical treatment, wage
loss, or disability insurance for federal employees who contract COVID-19.
• General considerations for reducing exposure, such as avoiding groups
and practicing social distancing.
On July 6, 2020, OLEM published the Interim EPA COVID-19 Health & Safety
Guidelines for Field Activities. These guidelines, which were issued after we
surveyed OSCs for our evaluation:
[R]epresent an integrated set of safety and health guidance that
provide timely and consistent information for employees
conducting field activities. These Guidelines merge several
Agency program-specific COVID-19 health and safety guidance
documents into an overall document to address COVID-19-related
concerns applicable to field activities.
Multiple EPA regions have also developed their own guidance documents. These
were typically developed prior to the OLEM guidance documents and address
region-specific issues.
Federal Emergency Management Agency Developed Pandemic Operational Guidance for 2020 Hurricane Season To help federal, state, local, tribal, and territorial emergency managers and public
health officials respond to incidents during the 2020 hurricane season amid the
coronavirus pandemic, the Federal Emergency Management Agency released the
COVID-19 Pandemic Operational Guidance for the 2020 Hurricane Season in
May 2020.
The purpose of this document was to provide actionable guidance to federal, state,
local, tribal, and territorial officials to prepare for response and recovery
operations. It encourages that personal preparedness measures be taken during the
coronavirus pandemic. While the guidance focuses on hurricane season
preparedness, most of the planning considerations within the guidance are
intended to also apply to any disaster operation during the coronavirus pandemic,
including no-notice incidents, spring flooding, wildfires, and typhoons. The
guidance includes a checklist for state, local, tribal, and territorial officials and
20-E-0332 4
addresses issues such as stockpiling PPE, deciding which staff will be deployed,
and determining how staff will be protected.
Responsible Offices
The Office of Emergency Management within OLEM and the Superfund and
Emergency Management divisions in the EPA regions are responsible for the
subjects covered in this report.
The Office of Emergency Management
works with federal partners to prevent
accidents and maintain incident response
capabilities. The regional Superfund and
Emergency Management divisions identify, investigate, and clean up
contaminated sites and protect public health and the environment from releases of
hazardous substances.
Scope and Methodology
We conducted this evaluation from May to August 2020 in accordance with the
Quality Standards for Inspection and Evaluation published in January 2012 by
the Council of the Inspectors General on Integrity and Efficiency. Those standards
require that we plan and perform the evaluation to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings, conclusions, and
recommendations based on our review objectives. We believe that the evidence
obtained provides a reasonable basis for our findings, conclusions, and
recommendations.
We reviewed EPA emergency response activities and guidance from March
through July 2020. We interviewed regional Superfund and Emergency
Management Division directors from all ten EPA regions and from headquarters,
as well as Office of Emergency Management managers, to determine whether the
EPA:
• Managed its resources to provide continued protection of human health
and the environment at emergency response sites during the coronavirus
pandemic.
• Provided sufficient protective measures to OSCs responding to emergency
incidents.
We sent a survey to 239 OSCs on June 9, 2020, to determine whether the EPA
provided sufficient protective measures to those OSCs responding to incidents.
The survey closed on June 23, 2020, and 127 OSCs across all ten EPA regions
responded—a response rate of 53 percent. Appendix A contains the OSC
survey results.
The EPA’s Superfund program is “responsible for cleaning up some of the nation’s most contaminated land and responding to environmental emergencies, oil spills and natural disasters.”
—EPA’s Superfund website
20-E-0332 5
Results
EPA regions sufficiently protected human health and the environment by
responding to or assisting in responses during the coronavirus pandemic. In
addition, the Agency took some initial measures to protect OSCs. For example,
starting in March 2020, when the EPA began adjusting its operations in response
to the coronavirus pandemic, the Agency reviewed its ongoing and time-critical
emergency responses, delaying its response actions when possible to do so
without further detriment to public health or the environment. Also, some OSCs
who normally would have been deployed were instead able to work remotely with
state and local responders to verify that emergency responses were adequate.
Some OSCs who responded to our survey, however, expressed concerns that the
EPA did not provide sufficient protective measures or effectively manage its
emergency responses during the pandemic:
• About half of the OSCs reported that the coronavirus pandemic impacted
their ability to respond to emergencies. Some cited delays in procuring
PPE and cleaning supplies, while some said there were delays due to the
additional time needed to obtain approval for deployment. Other OSCs
said that they were unable to obtain PPE or cleaning supplies or that some
received PPE was expired. No survey responses indicated that the delays
caused an impact on public health or the environment.
• All of the OSCs said that the EPA did not provide COVID-19 tests to
them before or after deployment.
• Although almost all of the OSCs indicated that they were familiar with
OLEM’s health and safety guidance, some said that they had issues
complying with the guidance. For example, some OSCs said that it was
difficult to make sure an emergency medical technician was on-site, as
required. Other OSCs said that they needed clarification on the guidance,
such as what procedures to follow if they became sick during deployment
and which face coverings to wear.
OSCs and management sometimes had different observations on the availability
of PPE and cleaning supplies. For example, regional Superfund and Emergency
Management Division directors told us during interviews that PPE and other
supplies were provided to OSCs, while some OSCs indicated that they could not
obtain some PPE and supplies.
Superfund and Emergency Management Division directors also told us about the
implications of the coronavirus pandemic on the Agency’s impending emergency
responses during the 2020 hurricane and wildfire seasons. One western region
indicated that it may be unable to respond to large incidents because of a lack of
and supplies, especially N95 masks, which it deems necessary for wildfire
responses.
20-E-0332 6
While the effect of the pandemic on emergency responses to large, nonpandemic
incidents was not explicitly part of our project scope, we posed the question to
regional Superfund and Emergency Management Division directors because of its
relevance to the OSCs’ ability to effectively deploy during the pandemic. Given
the issues described by the OSCs in obtaining supplies, large-scale mobilization
of OSCs and other EPA staff from multiple regions in response to large incidents,
such as hurricanes or wildfires, may prove challenging. Such an event would
further increase demands for pandemic-related supplies and require additional
logistics planning, such as travel and housing arrangements.
EPA Has Sufficiently Managed Emergency Responses During the Coronavirus Pandemic
Since March 2020, EPA regions reviewed their ongoing and time-critical
emergency responses, delaying response actions when possible to do so without
further detriment to public health or the environment. In addition, some OSCs
who normally would have been deployed were instead able to remotely
coordinate emergency responses with state and local responders.
We found that OSCs had been deployed to fewer emergencies since March 2020.
While this may have been partially due to regions eliminating nonessential
deployments, most regions indicated that the number of emergency response
incidents was reduced during the pandemic. According to the EPA On-Scene
Coordinator (OSC) Response Website, the number of emergency removals
conducted in 2020 from March 15 through June 15 was significantly below those
conducted in the same months in prior years (Figure 1). “Emergency removals”
are also referred to as “classic emergencies,” which the EPA defines as situations
that require “on-site activities be initiated within minutes or hours of a
determination that … action is appropriate.”
Figure 1: Number of emergency removals per year (March 15–June 15)
Source: OIG analysis of EPA On-Scene Coordinator (OSC) Response Website data. (EPA OIG image)
68
58 57
76
22
2016 2017 2018 2019 2020
20-E-0332 7
Some OSCs Experienced Delays in Obtaining PPE and Supplies
Despite the initial protective measures taken by the EPA, many OSCs reported
concerns about protection during the coronavirus pandemic. For example, about
half (61 of 127) of the OSCs responding to our survey reported that the pandemic
impacted their ability to respond to emergencies (Figure 2). These OSCs cited
delays in procuring PPE and cleaning supplies or the inability to obtain these
supplies altogether; the receipt of expired PPE; and
delays due to the additional time needed to obtain
approval for deployment. Moreover, OSCs and some
Superfund and Emergency Management Division
directors reported that the EPA did not provide COVID-
19 tests to any of the OSCs before or after deployment.
Our OSC survey results and interviews with regional
Superfund and Emergency Management Division
directors revealed differing perceptions regarding the
availability of needed supplies. While the regional
directors indicated that they provided these supplies to
OSCs, some OSCs reported difficulty obtaining them.
Our survey results showed that most OSCs who
responded to our survey were provided with most—
but not all—of the needed supplies. As Figure 3
shows, more than 60 percent of the 127 OSCs who responded to our survey
reported that the EPA had provided N95 masks (77), gloves (100), sanitizers (90),
and disinfectants (85). However, about 9 percent (11) reported that the EPA did
not provide any of the needed supplies.
Figure 3: Percent of OSCs reporting EPA provided supplies*
Source: OIG OSC survey responses. (EPA OIG image)
* Percent of the 127 respondents. Respondents could choose more than one option to indicate all supplies provided by the EPA. Note: The Interim EPA COVID-19 Health & Safety Guidelines for Field Activities, published after this survey was completed, indicates that cloth masks are acceptable in most conditions and that “N95 respirators should not be recommended for use without being identified through a hazard assessment.”
77, 61%
100, 79%
90, 71%85, 67%
11, 9%
45, 35%
N95 masks gloves sanitizers disinfectants none other
Figure 2: Pandemic impact on OSCs to respond to emergencies
Source: OIG OSC survey. (EPA OIG image)
Survey Question: Has the coronavirus pandemic impacted your ability to respond to emergencies?
Yes, 6148%
No, 6652%
20-E-0332 8
When asked whether they were unable to obtain any supplies, almost 65 percent
(82) of our 127 survey respondents indicated that obtaining supplies was not an
issue. However, the 35 percent (45) who could not obtain some supplies said that
N95 masks, sanitizers, and disinfectants were the most difficult for them to obtain
(Figure 4). Figure 4 documents supplies that could not be obtained, not whether
they were supplied by the EPA, as illustrated in Figure 3. Figure 4: Supplies OSCs could not obtain*
Source: OIG OSC survey responses. (EPA OIG image)
* Percent of the 127 respondents. Respondents could choose more than one option to indicate all supplies they were not able to obtain. Note: The Interim EPA COVID-19 Health & Safety Guidelines for Field Activities, published after this survey was completed, indicates that cloth masks are acceptable in most conditions and that “N95 respirators should not be recommended for use without being identified through a hazard assessment.”
EPA Needs to Plan for Large Natural Disaster Incidents
All regions indicated that they would follow normal procedures if they
experienced a shortage of OSCs. Based on our survey and interviews, no region
experienced such a shortage as of June 2020. Normal procedures during an OSC
shortage involve requesting assistance from designated backup regions. In
addition, for a large incident, such as a wildfire or hurricane, the EPA would
deploy OSCs from regions beyond the designated backup regions. Regional
management told us, however, that large-scale responses would be complicated
by restrictions due to the coronavirus pandemic, such as limited travel and the
unavailability of supplies.
For example, the Superfund and Emergency Management Division director in one
region identified a potentially critical issue regarding PPE availability. According
to the director, N95 masks are necessary to protect OSCs during wildfire
incidents, and without N95 masks the region cannot safely deploy OSCs to
respond. The director said that although N95 masks were readily available prior to
the coronavirus pandemic, the masks have become more difficult to obtain
because of the increased demand for these masks for medical personnel. Without
25, 20%
13, 10%
27, 21% 27, 21%
20, 16%
N95 masks gloves sanitizers disinfectants other
20-E-0332 9
a sufficient inventory of N95 masks, consistent with Federal Emergency
Management Agency guidance to stockpile PPE, effective deployment of OSCs
during a wildfire would be impaired. This issue primarily concerns EPA
Regions 8, 9, and 10.
Office of Emergency Management managers indicated that procurement of all
supplies was up to EPA regions and that there was no national strategy for
procurement and distribution of supplies to the regions.
Given the OSCs’ issues in obtaining supplies and the potential unavailability of
N95 masks for wildfire responses, planning for impending responses to large
incidents during the pandemic is imperative. Issues that need to be addressed
include the sufficient availability of supplies to provide pandemic protection to
OSCs while responding to large incidents, as well as additional guidance for the
deployment and safety of large numbers of OSCs and other EPA personnel.
OSCs Familiar with Guidance but Need Some Clarifications
Almost all OSCs who responded to our survey (123 of 127, or 97 percent)
reported that they were familiar with the OLEM health and safety guidelines.
Most of the OSCs (100 of 123 who answered the question, or 81 percent) reported
that the guidelines available at the time adequately protected OSCs.
Some OSCs reported issues complying with the guidelines. For example, they had
difficulty obtaining emergency management technicians to assist at each site and
accessing PPE and supplies. In addition, some OSCs said that they needed
clarifications on the guidelines, specifically:
• How to protect family members.
• Which procedures to follow if they became sick while deployed, and
whether and how to fly home.
• Which face coverings to use, and when.
• How long an N95 mask remains effective.
• How and when to be tested for COVID-19.
• How to operate safely in indoor spaces.
• How to apply for workers’ compensation as it relates to the coronavirus
pandemic.
• Who makes decisions on when OSCs should quarantine.
• Whether federally or privately owned vehicles can be used during a
pandemic.
Due to details or nuances in the comments provided by our survey respondents,
we could not readily determine whether the issues have been explicitly addressed
in the July 6, 2020 Interim EPA COVID-19 Health & Safety Guidelines for Field
Activities, which was issued by OLEM after the OSC survey was completed.
20-E-0332 10
Conclusions
EPA regions acted to protect OSCs and provide them with some needed supplies
while retaining emergency response capabilities. However, 35 percent of the
OSCs responding to our survey reported that they were unable to obtain some
supplies. We identified areas of concern for OSCs and regional emergency
response capabilities. OSCs may not be safe deploying during the coronavirus
pandemic without receiving clarifications on the guidelines, and they will be at
risk if they cannot obtain sufficient PPE or other supplies. Their specific concerns
about safety may not be explicitly addressed in the EPA’s guidelines issued as of
July 2020.
A director from one EPA region indicated that the region may be unable to safely
deploy OSCs in the event of major wildfires because of the lack of N95 masks.
Moreover, there is no national EPA strategy for the procurement and distribution
of PPE and cleaning supplies to regions and OSCs. Without a national strategy or
coordination of regional efforts, some OSCs may not be able to readily obtain
adequate PPE and supplies to deploy safely. Responses to large incidents are not
explicitly addressed in the guidance documents and may be difficult because of
limited travel and other complications arising from the coronavirus pandemic.
Recommendations
We recommend that the assistant administrator for Land and Emergency
Management, in coordination with all EPA regions:
1. Develop and implement a strategy to provide and distribute necessary
personal protective equipment and cleaning supplies to on-scene
coordinators, including the N95 masks needed to respond to wildfires.
2. Develop and implement communication mechanisms to identify and
clarify concerns that on-scene coordinators have that are not addressed in
the existing guidelines, and make these communications available to all
on-scene coordinators.
3. Ensure that guidance and planning address deployment of on-scene
coordinators in the event of large incidents during pandemics, including
overcoming travel restrictions to respond to large incidents.
4. Pursue the acquisition of COVID-19 tests for all on-scene coordinators
prior to and immediately after deployment.
20-E-0332 11
Agency Response and OIG Assessment
The assistant administrator for Land and Emergency Management responded to
our draft report. We included this response, as well as our full analysis of this
response, in Appendix B. The Agency agreed with Recommendation 2 and
provided an acceptable planned corrective action and estimated completion date.
This recommendation is resolved with corrective action pending. The Agency
disagreed with Recommendations 1, 3, and 4. The Agency provided alternate
recommendations, but these alternate recommendations either did not include
specific planned corrective actions or did not adequately address our findings.
These recommendations therefore remain unresolved.
20-E-0332 12
Status of Recommendations and Potential Monetary Benefits
RECOMMENDATIONS
Rec. No.
Page No. Subject Status1 Action Official
Planned Completion
Date
Potential Monetary Benefits
(in $000s)
1 10 In coordination with all EPA regions, develop and implement a strategy to provide and distribute necessary personal protective equipment and cleaning supplies to on-scene coordinators, including the N95 masks needed to respond to wildfires.
U Assistant Administrator for Land and Emergency
Management
2 10 In coordination with all EPA regions, develop and implement communication mechanisms to identify and clarify concerns that on-scene coordinators have that are not addressed in the existing guidelines, and make these communications available to all on-scene coordinators.
R Assistant Administrator for Land and Emergency
Management
3/31/21
3 10 In coordination with all EPA regions, ensure that guidance and planning address deployment of on-scene coordinators in the event of large incidents during pandemics, including overcoming travel restrictions to respond to large incidents.
U Assistant Administrator for Land and Emergency
Management
4 10 In coordination with all EPA regions, pursue the acquisition of COVID-19 tests for all on-scene coordinators prior to and immediately after deployment.
U Assistant Administrator for Land and Emergency
Management
1 C = Corrective action completed. R = Recommendation resolved with corrective action pending. U = Recommendation unresolved with resolution efforts in progress.
20-E-0332 13
Appendix A
OSC Survey Results
The OIG distributed an electronic survey to 239 OSCs on June 9, 2020, and asked them to
respond within two weeks. We received 127 responses, a 53 percent response rate. Not all
respondents answered every question. The results included 11 responders who were on the OSC
email lists but self-identified in the survey as a “manager” or “other.” The data source for all
figures and tables presented in this appendix, which are EPA OIG images and tables, is the
survey results.
Question 1: Has the coronavirus pandemic impacted your ability to respond to emergencies?
The results of the first question were split, with 52 percent (66 responses) indicating there was no
impact and 48 percent (61 responses) indicating there was an impact. See Figure 2 in the report.
Question 2: (If “Yes” to the first question) Select all that apply.
For those respondents indicating that there was an impact, the reasons were:
Impact Number
Delays in obtaining cleaning supplies such as sanitizers or disinfectants 24
Delayed due to obtaining personal protective equipment, such as masks or gloves 20
Delayed because you were quarantined 15
Delays due to contractor availability 3
Your or others on your team were ill due to COVID-19 2
Other 44
The “Other” category included the following types of responses:
“Other” Responses Number
Administrative policies including additional approval needed 21
Concerns over exposure to COVID-19 5
Lack of plans 5
Policy to not respond to minor incidents 4
No or limited PPE availability 4
OSC declined to deploy due to health concerns 3
Delays in obtaining government owned vehicles 2
20-E-0332 14
Question 3: What supplies has the EPA provided the OSCs during the coronavirus pandemic?
Many OSCs indicated that the EPA provided many of the supplies needed for emergency
response during the pandemic. A majority of the respondents indicated that they received masks,
gloves, sanitizers, and disinfectants from the EPA. About 9 percent of OSCs indicated that they
did not receive any supplies from the EPA. See Figure 3 in the report.
Questions:
4: Were you unable to obtain any supplies?
5: Select all that apply: (For “No” responses to Question 4.)
A majority, 82 of 127, or 65 percent, of respondents indicated that they were able to obtain the
supplies they needed from the EPA, while 35 percent stated that they were unable to obtain
needed supplies from the EPA. More than 20 percent of respondents indicated they could not
obtain N95 masks, sanitizers, or disinfectants. See Figure 4 in the report.
Yes, 45, 35%
No, 82, 65%
20-E-0332 15
Question 6: How many times have you been deployed since March 15, 2020?
Of the 127 respondents, 84 (66 percent) were not deployed, while 43 (34 percent) were deployed
at least once. Seventeen (13 percent) were deployed multiple times.
Questions:
7: In your official capacity, have you been tested for COVID-19 in deployments since March 15, 2020?
8: How many times were you tested prior to deployment?
9: How many times were you tested after deployment?
10: Did the EPA arrange for or provide the testing?
11: How quickly did you receive your test results?
12: Please provide any relevant details.
All respondents stated that they had not been tested in their official capacity for COVID-19
either before or after deployments.
84, 66%
26, 21%
17, 13%
0 1 Multiple times
20-E-0332 16
Questions:
13: Have you been asked to respond to emergencies because of a state’s or local municipality’s inability to provide emergency response due to the coronavirus pandemic?
14: Have you been deployed to another EPA region due to depleted resources in that region due to the coronavirus pandemic?
Almost all (94 percent) respondents stated that they had not been asked to respond to
emergencies because of a state or local municipality’s inability to provide emergency response
due to the coronavirus pandemic. All respondents stated that they had not been deployed to
another EPA region due to depleted resources in that region.
Question 15: Have the funds available from the Coronavirus Aid, Relief, and
Economic Security Act, known as the CARES Act, been used to clean and disinfect equipment?
No OSCs indicated that funds from the Act were used to clean and disinfect equipment. Most
(90 percent) indicated that they did not know.
Questions:
16: Are you familiar with the EPA’s "Interim Health and Safety Guidelines Related to COVID-19 for Conducting Superfund Site Work – 4/21/2020"?
17: Do you have any issues or difficulties complying with the guidelines?
18: Please elaborate: (For “Yes” responses to Question 17)
Almost all (97 percent) respondents were familiar with the Interim Health and Safety Guidelines
Related to COVID-19 for Conducting Superfund Site Work – 4/21/2020. Most (83 percent)
indicated that they had no issues or difficulties in complying with the guidelines. Some
respondents (17 percent) stated that they had issues or difficulties in complying with the
guidelines. Those that had difficulty cited various reasons.
Yes, 2117%
No, 10283%
20-E-0332 17
Issues with or difficulties complying with the guidelines Total
respondents
Presence of an emergency medical technician – Difficult or impossible to ensure an emergency medical technician was on-site.
5
Travel – Concerns about how OSCs take care of themselves and who pays if they are quarantined or sick.
3
Supplies – Concerns about the availability of masks, gloves, disinfectants, sanitizers, and thermometers.
14
Testing – Questions about why no testing is available for OSCs. 2
General comments – Guidelines were late and unrealistic for real world field use. 5
Most (81 percent) respondents also indicated that, in their opinion, the guidelines adequately
protected OSCs. In addition, almost all (91 percent) respondents stated that their individual
region provided additional guidance for OSCs, with 9 percent in six different regions stating that
their region did not.
Questions:
19: In your opinion, do the guidelines adequately protect OSCs?
20: Please elaborate: (For “No” responses to Question 197)
Some respondents (19 percent) stated that, in their opinion, the guidelines did not adequately
protect OSCs.
Reasons OSCs believed guidelines did not adequately protect OSCs Total
respondents
Travel – Unclear about how OSCs would take care of themselves and who pays if they are quarantined or sick.
6
Supplies – Unclear about the availability of masks, gloves, disinfectants, sanitizers, and thermometers. Noncommittal about what type of masks to use and whether N95 masks can be reused.
8
Testing –Unclear about whether COVID-19 testing with rapid response times is needed for OSCs.
6
General comments – Do not adequately address when or whether OSCs should deploy.
7
In addition to specific questions, OSCs were asked to provide any additional relevant information
not explicitly covered in the survey.
Additional relevant information Total
respondents
Travel – Guidelines unclear about who makes the decision to quarantine and who helps provide protection for OSCs and their families
3
Supplies – Guidelines do not address the availability of supplies, with an emphasis on N95 masks.
11
Testing – Guidelines do not address EPA provided testing 3
General comments – A wide range of comments, such as difficulties in deciding to deploy or not.
17
Positive comments – Some of the respondents commented that management and supervisors have done their best to protect OSCs
9
20-E-0332 18
Appendix B
Agency Response to Draft Report
Thank you for the opportunity to respond to the issues and recommendations in the subject
report. The following is a summary of the Office of Land and Emergency Management’s
(OLEM) overall position, along with its position on each of the report recommendations. Note
that this preliminary response may not reflect the views of other Agency organizations such as
the Office of the Chief Financial Officer (OCFO) and the Office of Mission Support (OMS).
EPA agrees with one of the report recommendations and has provided high-level corrective
actions and estimated completion dates to the extent possible. EPA disagrees with the other three
report recommendations and has provided a response and proposed alternative recommendations
as appropriate.
EPA recognizes that the COVID-19 pandemic is a very fluid situation, and the agency is
committed to continually providing timely and adequate guidance to the evolving circumstances.
To that extent, OLEM has also contacted several other federal agencies to gain a better
understanding of their internal guidances pertaining to COVID-19 and their responders. The
results of those inquiries were not readily available to meet this response deadline.
20-E-0332 19
AGENCY'S OVERALL POSITION
EPA appreciates the Office of Inspector General's interest in conducting an evaluation of the
Agency’s efforts to protect human health and the environment by responding to emergencies or
assisting in emergency responses during the coronavirus pandemic, and its established protective
measures for EPA’s On-Scene Coordinators (OSCs). However, EPA views the methodology and
evidence that support the recommendations flawed in two ways:
1) Despite the report acknowledging that additional EPA guidance had been published,
within the scope of the evaluation, the recommendations and statements in the report do
not reflect elements that the guidance successfully addressed.
2) A survey, particularly one containing broad prompts that do not apply to a significant
number of respondents, is not a sufficient evaluative methodology to support the
conclusions within the report.
OIG Response 1: As stated in the report, we could not readily confirm whether the July 6,
2020 guidance explicitly addressed the concerns expressed by the OSCs in our survey because
of details or nuances in their survey responses. Further, we note that the survey was completed
prior to the release of the guidance. Our conclusions are based on the survey responses and on
our interviews with all ten regional Superfund and Emergency Management Division directors,
as defined in the “Scope and Methodology” section of the report.
Guidance governing employee health and safety is a significant concern for all federal agencies
during this pandemic, and, given the frontline nature of the response duties of the Agency’s On-
Scene Coordinators, even more critical to the EPA. It is for this reason that the EPA Response
Program is leveraging the best available information from the Centers for Disease Control and
Prevention (CDC), Occupational Safety and Health Administration (OSHA), Federal Emergency
Management Agency (FEMA), and EPA’s own agency guidance to provide the best information
and guidance to those OSCs in the field.
EPA’s latest and most comprehensive guidance on field operations during the COVID-19
pandemic was published on July 6, 2020. This guidance falls well into the scope of the report
which states it “conducted this evaluation from May to August 2020”1. The guidance, entitled,
COVID-19 Health and Safety Guidelines for Field Activities, incorporates employee safety
recommendations from CDC, OSHA, and FEMA as well as previous EPA guidance. Many of
the issues raised in this OIG report are comprehensively addressed in this July 6th guidance. That
guidance provides actionable and specific operational guidance on respiratory protection, safety
training and medical clearance, pre-travel considerations, travel related recommendations, and
workplace illness and injuries. In addition, offices responsible for workforce health and safety,
such as Office of Mission Support’s Safety and Sustainability Division, were not consulted at
1 “EPA Has Sufficiently Managed Emergency Responses During the Pandemic but Needs to Procure More Supplies
and Clarify Guidance”. Office of the Inspector General. Page 4.
20-E-0332 20
any point during the evaluation. The evolving nature of the pandemic has been a challenge that
the EPA has met with evidence-based management and decision-making.
OIG Response 2: The statement “conducted this evaluation from May to August 2020” refers
to the entrance conference in May and the issuance of the draft report in August. We began
drafting our report after the survey closed on June 29, and the report reflects the information
available at that time. We recognize that Agency operations and guidance have evolved during
the pandemic. However, it is valuable to report on what OSCs and regional Superfund and
Emergency Management Division directors were experiencing early during the pandemic for
use in future guidance. In addition, when we provided OLEM with the scope of our work at the
entrance conference in May, OLEM did not indicate that we should meet with the Office of
Mission Support. When we interviewed Office of Emergency Management staff in June, they
referenced some of their interactions with the Office of Mission Support but did not suggest
that we consult with that office.
The OIG report and recommendations include several courses of action that diverge substantially
from both EPA guidance and guidance from other Federal Agencies:
• Usage of N95 respirators and other PPE
• Overcoming travel restrictions
• COVID-19 testing pre- and post- deployment
This response document includes specific explanations and proposed actions to these issues
below. Generally, the effectiveness of the EPA Response Program’s OSC safety guidance
should be evaluated on the basis of the current guidance, the evidence that supports it, and the
Agency’s implementation of that guidance. By not integrating the EPA’s most comprehensive
and current guidance available during the scope of the evaluation or speaking to those offices
chiefly responsible for setting health and safety policy, the report and recommendations for the
safety protections for OSCs is of significantly diminished value.
The report asserts that the survey data, as evidence, “provides a reasonable basis for our findings,
conclusions, and recommendations based on our review”2. EPA disputes that assertion. The
survey’s methodology is flawed and has limited evaluative value to support the findings and
recommendations contained in the report. EPA asserts the report and recommendations’
divergence from established guidance from EPA and other Federal Agencies is due to its reliance
on a survey that lacked population control methodology and featured questions not aligned to
available evidence-based information.
2 “EPA Has Sufficiently Managed Emergency Responses During the Pandemic but Needs to Procure More Supplies
and Clarify Guidance”. Office of the Inspector General. Page 4.
20-E-0332 21
OIG Response 3: The OIG disagrees that the methodology is flawed and has limited
evaluative value. The survey questions are unbiased, and the results are direct responses to the
survey questions. In addition, the OIG met with all ten regional Superfund and Emergency
Management Division directors, whose input was also used to form conclusions in this report.
The OIG disagrees that the courses of action diverge substantially from both EPA and other
federal guidance. The OIG, with the direct involvement of senior management, took steps to
ensure that the survey did not ask leading questions.
Two statements in the EPA’s response need clarification:
• “lacked population control methodology.” The survey was distributed to all OSCs.
• “not aligned to available evidence-based information.” Survey results are a direct form of
evidence. Testimonial evidence is one of the types of evidence defined in the Quality
Standards for Inspection and Evaluation and is defined as “obtained through inquiries,
interviews or questionnaires.”
The survey’s questions are written without incorporating the evidence-based guidance from EPA
and other Federal Agencies. For example, the questions related to PPE do not take into account
the May 2020 OSHA guidance, Guidance on Preparing Workplaces for COVID-19, that clearly
describes in which situations employees need various respiratory protection for potential
exposure to COVID-19. As not every deployment requires respirator protection, according to the
OSHA guidance, more detailed questions than the report’s survey asked would be required to
establish if there was an actual need for a recommendation.
For example, to establish the report’s recommendation for N95 respirators the survey asked the
following: “4: Were you unable to obtain any supplies? 5: Select all that apply: (For “No”
responses to Question 4.)”3. To adequately evaluate if the Agency was following OSHA
employee safety guidance, the following question would provide more evaluative value: “Were
you able to obtain N95 or equivalent respirators, before deployment, if the deployment had
persons known to be, or suspected of being, infected with SARS-CoV-2 or while performing
aerosol-generating procedures?”4 OSC answers to this evidenced-based question would have
evaluative value. However, the original question provides limited information on which to base a
recommendation.
3 “EPA Has Sufficiently Managed Emergency Responses During the Pandemic but Needs to Procure More Supplies
and Clarify Guidance”. Office of the Inspector General. Page 13. 4 “Guidance on Preparing Workplaces for COVID-19”. Occupational Safety and Health Administration. Page 15.
20-E-0332 22
OIG Response 4: The use of N95 respirators was standard practice for wildfire responses prior
to the pandemic. The Agency’s clarification that cloth masks were acceptable in most
conditions was not provided until the EPA issued its July 6, 2020 guidance. More importantly,
Recommendation 1 references N95 respirators only for responses to wildfires, which the
Agency retained in its proposed revision. In response to Agency comments, we added the
following note to Figures 3 and 4:
The Interim EPA COVID-19 Health & Safety Guidelines for Field Activities,
published after this survey was completed, indicates that cloth masks are
acceptable in most conditions and that “N95 respirators should not be
recommended for use without being identified through a hazard assessment.”
In addition to the lack of evidence specificity in the questions, there was a lack of controls for
survey population. For example, asking the survey respondent OSCs who had not been deployed
(66% of the total) if they received PPE is premature. OSCs who had not yet deployed would not
require PPE. This fact was not controlled for in the analysis. In addition, many OSCs were at the
time of the survey, and continue to be, teleworking and would not require PPE. Neither of these
populations were removed from the survey questions related to PPE or travel. The evaluative
value of that data as it has been analyzed is too weak to make the findings or recommendations
the report contains.
OIG Response 5: The purpose of the survey was to determine how protected OSCs felt during
the pandemic. These results, such as OSC perceptions of the availability of PPE, represent the
opinions of the responding OSCs. Some OSCs who indicated that they had difficulty obtaining
some or all PPE had been deployed since March 2020, when the EPA began adjusting its
operations in response to the pandemic. Further, only nine, or 7 percent, of the respondents said
that they had received no PPE or other supplies from the Agency, indicating that almost all
OSCs had received some supplies.
The important issue is that many OSCs indicated that they had not received, or could not
obtain, PPE and other supplies. The Agency’s general response to our report regarding PPE is
inconsistent with its response to our recommendations. Specifically, the Agency’s proposed
revisions to Recommendation 1 confirm its commitment to obtaining and distributing PPE and
other supplies to OSCs, and the Agency agreed with Recommendation 2 to enhance
communication with OSCs to address any concerns they may have.
In sum, EPA has serious concerns about the report’s reliance on survey responses, and the fact
that it wholly disregards the Agency’s ongoing efforts to address the very topic upon which it
opines.
20-E-0332 23
OIG Response 6: This report addresses whether sufficient protective measures were provided
to OSCs based on their survey responses. Further, the report also relies on the interviews of all
ten regional Superfund and Emergency Management Division directors. The report does not
disregard the Agency’s ongoing efforts to address the topic. The “Background” section
describes the guidance that the Agency has issued related to the pandemic, and the body of the
report references how regions protected OSCs by not deploying them for time-critical
responses if possible and allowing them to support emergency response efforts remotely.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
Recommendation
No.
Recommendation High-level Intended Corrective
Action
Estimated
Completion
Fiscal Year and
Quarter
2. Develop and
implement
communication
mechanisms to
identify and
clarify concerns
that on-scene
coordinators have
that are not
addressed in the
existing
guidelines, and
make these
communications
available to all on-
scene
coordinators.
Solicit feedback from OSCs via
several different mechanisms, such
as Q&A webinars with the OSC
community or regular meetings
with their management teams.
Document and maintain feedback
on a commonly accessible location
such as SharePoint or Microsoft
Teams. Any concerns that are not
adequately addressed within
existing guidelines will be
identified and addressed in a
follow-up document, and with
follow-up communication.
FY 2021, Q2
OIG Response 7: The planned corrective actions for Recommendation 2 meet the intent of the
recommendation. The Agency’s response also includes an estimated completion date. We
consider this recommendation resolved.
Disagreements
Recommendation
No.
Recommendation Agency
Explanation/Response
Proposed Alternative
1. In coordination
with all EPA
regions, develop
and implement a
EPA guidance on PPE,
COVID-19 Health and
Safety Guidelines for Field
Activities (Pages 2-5), is in
Regions will continue
to develop and
implement strategies to
provide and distribute
20-E-0332 24
Recommendation
No.
Recommendation Agency
Explanation/Response
Proposed Alternative
strategy to provide
and distribute
necessary personal
protective
equipment and
cleaning supplies
to on-scene
coordinators,
including the N95
masks needed to
respond to
wildfires.
accordance with OSHA’s
Guidance on Preparing
Workplaces for COVID-19.
Specifically, prior to
deployment field staff,
supervisors, and the local
Safety, Health and
Environmental Management
Program (SHEMP)
managers should follow
OSHA guidelines for
conducting a hazard
assessment to determine if
respirator usage or additional
PPE is required.
Respirator usage and PPE
determinations are made in
the Regions, not
headquarters. PPE
acquisition, inventory
management, and
distribution prior to and
during COVID-19 are
Regional responsibilities.
EPA does not support
shifting this responsibility
from the EPA Regions to
EPA Headquarters.
Longstanding acquisition
contracts and distribution
logistics in the Regions are
in place to provide PPE to
OSCs. No regions have
reported a shortage of PPE at
any point during the
pandemic.
Of those OSCs surveyed, 9%
of them stated that they were
not provided any PPE
supplies. With many OSCs
teleworking and a reduced
necessary personal
protective equipment
and cleaning supplies
to on-scene
coordinators, including
the N95 masks needed
to respond to wildfires.
20-E-0332 25
Recommendation
No.
Recommendation Agency
Explanation/Response
Proposed Alternative
number of deployments
some portion of the surveyed
population would be
expected not to receive PPE
at the time of the survey was
administered. They would
not have had a need for, or
recently received, PPE when
completing the survey.
66% of surveyed OSCs had
not been deployed since the
pandemic began. This was
not controlled for in
subsequent survey question
on PPE.
3. In coordination
with all EPA
regions, ensure
that guidance and
planning address
deployment of on-
scene coordinators
in the event of
large incidents
during pandemics,
including
overcoming travel
restrictions to
respond to large
incidents.
EPA does not support
providing guidance to EPA
personnel on “overcoming”
travel restrictions put in
place to protect public
health.
EPA has issued specific
guidance related to travel in
COVID-19 Health and
Safety Guidelines for Field
Activities (Pages 7-10) as a
supplemental to the existent
safety assessments.
That guidance states that
“Field staff traveling to areas
outside their home
jurisdictions should check
for additional (Local, State,
territorial, or Tribal)
requirements and include
them in their field work
planning and in the hazard
assessment process.”
EPA asserts that the OSC,
their supervisor, and the
In coordination with
all EPA regions,
ensure that prior to
performing field work
at a specific location,
the OSC, their
supervisor and the
local SHEMP manager
• Perform a
supplemental
hazard
assessment
addressing
COVID-19.
• Account for
Local, State,
territorial, or
Tribal travel
restrictions in
their work
planning.
20-E-0332 26
Recommendation
No.
Recommendation Agency
Explanation/Response
Proposed Alternative
local SHEMP manager are
best positioned to make
case-by-case evaluations for
deployments, consistent with
established agency guidance,
rather than nationwide
operational requirements.
4. In coordination
with all EPA
regions, pursue the
acquisition of
COVID-19 tests
for all OSCs prior
to and
immediately after
deployment.
Guidelines and potential
implementation of COVID-
19 employee testing is not
determined by OLEM.
Employee testing would be
governed by EPA agency
guidance issued by the
Office of Mission Support
(OMS).
EPA has utilized CDC’s
“CDC Activities and
Initiatives Supporting the
COVID-19 Response and
the President’s Plan for
Opening America Up
Again” in developing its
own agency guidance.
EPA’s current
guidance,COVID-19 Health
and Safety Guidelines for
Field Activities (Page 8,
Appendix B), instructs
OLEM to follow CDC’s
guidance Implementing
Safety Practices for Critical
Infrastructure Workers Who
May Have Had Exposure to
a Person with Suspected or
Confirmed COVID-19 to
provide guidance to OSCs.
Currently, that CDC
guidance is not
recommending COVID-19
testing pre- or post-
deployment.
In coordination with
all EPA regions,
ensure:
• All COVID-19
Testing
Guidance for
OSCs reflects
current EPA
and CDC
guidance.
• Implementation
of Employee
testing is
consistent with
current EPA
and CDC
guidance.
20-E-0332 27
Recommendation
No.
Recommendation Agency
Explanation/Response
Proposed Alternative
This is in accordance with
the CDC Testing Guidance
which states: “If you do not
have COVID-19 symptoms
and have not been in close
contact with someone known
to have a COVID-19
infection: You do not need a
test.”
In addition, the immediate
nature of OSC response
deployments would preclude
OSCs from completing
COVID-19 testing and
obtaining results prior to
deployment. Waiting to
deploy until a test sample is
processed could put human
lives and property at
immediate risk.
OIG Response 8: We consider Recommendations 1, 3, and 4 unresolved:
• Recommendation 1. The proposed revision appears to meet the intent of the original
recommendation but lacks an actionable planned corrective action with an estimated
completion date.
• Recommendation 3. The proposed revision does not address additional guidance and
planning that may be necessary when responding to large incidents.
• Recommendation 4. The proposed revision is vague and does not indicate whether
headquarters or regional pursuit of COVID-19 testing is acceptable, only that testing
should be consistent with CDC and EPA guidance. The EPA’s July 6, 2020 guidance
does not address testing. Furthermore, we do not agree that CDC guidance states that
testing is not necessary. Rather, the CDC considers government hazardous materials
responders as “critical infrastructure workers” and states that critical infrastructure
workers may need to be tested, according to their employer’s guidelines. Testing is
particularly important for regions that have a limited number of OSCs who may be
required to quarantine for 14 days post-deployment or who may be deployed for weeks
at a time. Depending on state or local restrictions, obtaining COVID-19 testing with
rapid results would potentially free quarantined OSCs for subsequent redeployment and
verify that OSCs on long deployments do not test positive.
20-E-0332 28
Appendix B
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff/Operations
Assistant Administrator for Land and Emergency Management
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Administrator
Deputy Assistant Administrator for Land and Emergency Management
Principal Deputy Assistant Administrator for Land and Emergency Management
Deputy Assistant Administrator for Land and Emergency Management
Director, Office of Emergency Management, Office of Land and Emergency Management
Director, Office of Superfund Remediation and Technology Innovation, Office of Land and
Emergency Management
Director, Office of Regional Operations
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Land and Emergency Management
Audit Follow-Up Coordinators, Regions 1–10
